Insider trading is back in the spotlight.  The SEC and FINRA are combatting insider trading on many fronts, including through the enforcement of requirements that broker-dealers implement procedures for preventing and detecting insider trading.  Recent statements from the agencies and enforcement actions illustrate that, while individual bad actors are still a clear target, broker-dealers that employ bad actors, or whose procedures do not adequately prevent or detect insider trading, may also find themselves in the agencies’ crosshairs, potentially facing large penalties or sanctions.